DB Plan & New Comparability PS Plan

[dmb]

A client with a DB plan is interested in adding a Age plus Service based PS plan. Deductibility isn't an issue. My concern is regarding non-discrimination. The DB plan is a standardized prototype plan. Can the plans be tested separately for non-discrim?? I'm fairly sure they can, but the one thing i come back to is the average benefits test. Would the DB benefits need to be included when performing the ABT on the PS plan??? Thanks.

[AndyH]

Yes, you can test separately or together (provided you meet the gateway requirements).

Re the ABPT, you need to include the other plan if the plan you are testing is being cross tested (dc on benefits or db on contribs)., or if you are testing together, one of the plans is being cross tested.

Otherwise you may disregard the other plan.

Example, you have a DB that must be general tested. The client also has a K plan. As long as the DB is tested on a benefits basis, you may disregard the K plan.

If instead the client has a PS plan that must be cross tested, you would need to pull in the DB plan to the ABPT whether or not it is in the NCT test.